Australia’s anti-money laundering laws have just changed in a way that will affect how we work with you, and in some cases, what information we’ll need to ask for. If you’ve noticed us asking more questions about the source of funds, the structure of your business, or the identity of people involved in transactions, this is why.
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill passed Parliament in November 2024, and the rules that sit underneath it were tabled in August 2025. These are the most significant changes to Australia’s AML laws in nearly two decades, and they apply both to existing regulated businesses like banks and payment providers, and to a new group of professions being brought into the regime for the first time.
What’s Actually Changing?
Until now, the AML/CTF regime largely applied to financial institutions. The Tranche 2 reforms expand compliance obligations from 1 July 2026 to apply to additional professions including accountants, lawyers, real estate professionals, property developers, and precious stone dealers.
New reporting entities that provide designated services will need to enrol with AUSTRAC by 29 June 2026 and comply with the Act by 1 July 2026. The regime is also being updated for existing regulated businesses, with the vast majority of changes for existing reporting entities needing to be implemented by 31 March 2026.
What This Means in Practice for You as a Client
The core of what changes is the due diligence process. The rules introduce more nuanced risk awareness and due diligence procedures based on customer risk levels, with enhanced due diligence required for high-risk clients including politically exposed persons, and simplified due diligence available for low-risk clients with appropriate documentation.
In plain terms, we’ll be required to verify who you are and, in some cases, understand the source of funds involved in transactions we assist with. For most clients, this will be a straightforward process. If you’re a longstanding client with a well-understood financial position, the practical impact will be minimal.
Where you might notice more questions from us is in situations that carry higher inherent risk under the new framework. These include transactions involving complex structures, trust arrangements with multiple beneficiaries, business sales or acquisitions, property transactions, and any situation where a third party is involved in funding or directing a transaction.
Law enforcement has often observed that professional service providers may be unwitting facilitators of money laundering schemes, which is precisely why the new laws focus on ensuring advisers understand who they’re dealing with and the nature of what they’re being asked to assist with. We take that responsibility seriously, and building these processes into how we work protects both our clients and our firm.
What We’re Doing to Prepare
As a reporting entity, we’re required to undertake a risk assessment of money laundering and terrorism financing risks we may face in providing designated services, develop and comply with AML/CTF policies to manage those risks, carry out customer due diligence before providing regulated services, and appoint an AML/CTF compliance officer to oversee day-to-day obligations.
We’re working through this carefully and ahead of the deadlines so that the impact on your day-to-day experience with us is as minimal as possible. AUSTRAC has stated it expects compliance assessments to be done in a light-touch way for small, low-complexity businesses, and has emphasised it wants to make compliance as efficient and cost-effective as possible for practices that have other regulatory obligations to meet. That’s the approach we’re taking internally.
For High-Net-Worth Individuals and Families
If you have a complex financial structure, multiple entities, international assets, or involvement in property transactions, it’s worth having a conversation with us about how these changes may affect your ongoing engagement. The questions we ask aren’t a sign that anything is wrong. They’re a standard part of the new compliance framework that applies across every client relationship, calibrated to the risk profile of the services being provided.
For Business Owners
If your business operates through a trust or company, or if we manage client funds, handle business transactions, act as a registered office, or assist with business sales and acquisitions on your behalf, our obligations under the new laws are likely to be more extensive. We may ask you to provide updated identification documents, information about beneficial ownership, or documentation about the source of funds involved in certain transactions.
Civil penalties under the AML/CTF Act can be imposed against individual directors and officers as well as their company, which means the obligations extend beyond us to you in certain circumstances. This is worth understanding, not as a cause for concern, but as context for why we’ll be more thorough in our documentation processes going forward.
Key Dates
The timeline has two main milestones. Existing regulated businesses such as banks and financial institutions must have updated their compliance frameworks by 31 March 2026. We, along with other accountants, lawyers, and real estate agents as newly regulated Tranche 2 professions, must be enrolled with AUSTRAC by 29 June 2026 and fully compliant by 1 July 2026.
If you have questions about how these changes might affect your specific situation or what information we may need from you, reach out to your Prime Partners adviser directly. It’s a much better conversation to have now than to be caught off guard later in the year.